SEC Company Response from VanEck ETF Trust (CIK 0001137360) — Apr 16, 2020
VanEck ETF Trust (CIK 0001137360)
Date: April 16, 2020 · CIK: 0001137360 · Accession: 0001137360-20-000130
AI Filing Summary & Sentiment
File numbers found in text: 333-123257, 811-10325
Letter
Washington, D.C. 20549 Attn: John Ganley, Division of Investment Management Re: VanEck Vectors ETF Trust (the “Trust”) (File Nos. 333-123257 and 811-10325)
Dear Mr. Ganley:
This letter responds to a comment from the U.S. Securities and Exchange Commission (the “Commission”) staff regarding the registration statement on Form N‑1A for the Trust with respect to VanEck Vectors India Growth Leaders ETF (formerly,VanEck Vectors India Small-Cap Index ETF) (the “Fund”), a series of the Trust, filed with the Commission on February 26, 2020.
In particular, it was requested that the Trust separately file on EDGAR as correspondence the completed fee table and expense example information for the Fund. Below please find the requested information:
Fund Fees and Expenses
The following tables describe the fees and expenses that you may pay if you buy and hold shares of the Fund (“Shares”).
Shareholder Fees (fees paid directly from your investment)
None
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Management Fee
0.50%
Other Expenses(a)(b)
0.32%
Total Annual Fund Operating Expenses(c)
0.82%
Fee Waivers and Expense Reimbursement(c)
0.00%
Total Annual Fund Operating Expenses After Fee Waivers and Expense Reimbursement(c)
0.82%
(a)
“Other Expenses” reflects the expenses at both the Fund and the Fund's wholly-owned subsidiary (the “Subsidiary”) levels.
(b)
Other Expenses have been restated to reflect current fees.
(c)
Van Eck Associates Corporation (the “Adviser”) has agreed to waive fees and/or pay Fund and Subsidiary expenses to the extent necessary to prevent the operating expenses of the Fund (excluding acquired fund fees and expenses, interest expense, trading expenses, taxes and extraordinary expenses of the Fund and the Subsidiary) from exceeding 0.85% of the Fund’s average daily net assets per year until at least May 1, 2021. During such time, the expense limitation is expected to continue until the Fund’s Board of Trustees acts to discontinue all or a portion of such expense limitation.
- 1 -
Expense Example
This example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. This example does not take into account brokerage commissions that you pay when purchasing or selling Shares of the Fund.
The example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your Shares at the end of those periods. The example also assumes that your investment has a 5% annual return and that the Fund’s operating expenses remain the same (except that the example incorporates the fee waivers and/or expense reimbursement arrangement for only the first year). Although your actual costs may be higher or lower, based on these assumptions, your costs would be:
YEAR
EXPENSES
$84
$262
$455
$1,014
* * * * *
If you have any questions, please feel free to contact Stephanie Chaung at (212) 698-3827 or me at (212) 698-3526.
Very truly yours,
/s/ Allison M. Fumai
Show Raw Text
CORRESP 1 filename1.htm Document Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.dechert.com ALLISON M. FUMAI allison.fumai@dechert.com +1 212 698 3526 Direct +1 212 698 3599 Fax April 16, 2020 U.S. Securities and Exchange Commission Judiciary Plaza 100 F Street, N.E. Washington, D.C. 20549 Attn: John Ganley, Division of Investment Management Re: VanEck Vectors ETF Trust (the “Trust”) (File Nos. 333-123257 and 811-10325) Dear Mr. Ganley: This letter responds to a comment from the U.S. Securities and Exchange Commission (the “Commission”) staff regarding the registration statement on Form N‑1A for the Trust with respect to VanEck Vectors India Growth Leaders ETF (formerly,VanEck Vectors India Small-Cap Index ETF) (the “Fund”), a series of the Trust, filed with the Commission on February 26, 2020. In particular, it was requested that the Trust separately file on EDGAR as correspondence the completed fee table and expense example information for the Fund. Below please find the requested information: Fund Fees and Expenses The following tables describe the fees and expenses that you may pay if you buy and hold shares of the Fund (“Shares”). Shareholder Fees (fees paid directly from your investment) None Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) Management Fee 0.50% Other Expenses(a)(b) 0.32% Total Annual Fund Operating Expenses(c) 0.82% Fee Waivers and Expense Reimbursement(c) 0.00% Total Annual Fund Operating Expenses After Fee Waivers and Expense Reimbursement(c) 0.82% (a) “Other Expenses” reflects the expenses at both the Fund and the Fund's wholly-owned subsidiary (the “Subsidiary”) levels. (b) Other Expenses have been restated to reflect current fees. (c) Van Eck Associates Corporation (the “Adviser”) has agreed to waive fees and/or pay Fund and Subsidiary expenses to the extent necessary to prevent the operating expenses of the Fund (excluding acquired fund fees and expenses, interest expense, trading expenses, taxes and extraordinary expenses of the Fund and the Subsidiary) from exceeding 0.85% of the Fund’s average daily net assets per year until at least May 1, 2021. During such time, the expense limitation is expected to continue until the Fund’s Board of Trustees acts to discontinue all or a portion of such expense limitation. - 1 - Expense Example This example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. This example does not take into account brokerage commissions that you pay when purchasing or selling Shares of the Fund. The example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your Shares at the end of those periods. The example also assumes that your investment has a 5% annual return and that the Fund’s operating expenses remain the same (except that the example incorporates the fee waivers and/or expense reimbursement arrangement for only the first year). Although your actual costs may be higher or lower, based on these assumptions, your costs would be: YEAR EXPENSES 1 $84 3 $262 5 $455 10 $1,014 * * * * * If you have any questions, please feel free to contact Stephanie Chaung at (212) 698-3827 or me at (212) 698-3526. Very truly yours, /s/ Allison M. Fumai Allison M. Fumai - 2 -